In conjunction with the Group of Seven (G7) leaders meeting in Italy earlier this month, key jurisdictions issued the latest in a series of coordinated economic restrictions on Russia in light of its invasion of Ukraine in...more
7/1/2024
/ Belarus Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Transactions ,
Foreign Financial Institutions (FFI) ,
Foreign Trade Regulations ,
G7 ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Technology ,
UK ,
Ukraine
Medical device companies have a new regulatory pathway for exporting certain U.S.-origin medical products to Russia, Belarus, Crimea and other regions of Ukraine (i.e., the so-called Donetsk People’s Republic and Luhansk...more
5/6/2024
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Crimea ,
Entity List ,
Exceptions ,
Export Controls ,
General Licenses ,
Medical Devices ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Regulatory Requirements ,
Russia ,
TSRA ,
Ukraine
On April 24, 2024, President Biden signed into law H.R. 815, an emergency appropriations package billed as authorizing $95 billion in foreign aid to Ukraine and Israel (the Act). While the Ukraine and Israel aid provisions...more
4/30/2024
/ Appropriations Bill ,
Biden Administration ,
China ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
Federal Budget ,
FinCEN ,
Foreign Financial Institutions (FFI) ,
Israel ,
Russia ,
TikTok ,
UK ,
Ukraine
On March 6, 2024, the U.S. Departments of the Treasury, Commerce, and Justice jointly issued a Tri-Seal Compliance Note titled “Obligations of Foreign-Based Persons to Comply with U.S. Sanctions and Export Control Laws”...more
Companies faced with the decision of whether to voluntarily self-report sanctions breaches to law enforcement or sanctions enforcement agencies in the UK and the US can take some measure of comfort from recent comments made...more
10/16/2023
/ Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Good Faith ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Self-Reporting ,
Serious Fraud Office (SFO) ,
U.S. Commerce Department ,
U.S. Treasury ,
UK ,
Voluntary Disclosure
On May 19, in response to Russia’s ongoing invasion of Ukraine, the United States, in coordination with allies and partners, announced new sanctions restrictions and export controls targeting Russia’s evasion networks,...more
6/5/2023
/ Asset Freeze ,
Avoidance ,
Banking Sector ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Energy Sector ,
EU ,
Executive Orders ,
Export Controls ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
UK ,
Ukraine
Western sanctions against Russia have continued to broaden substantially into new areas of trade, especially in the energy sector. Policymakers in Washington DC, Brussels, London and other allied capitals also continue to...more
3/18/2022
/ Asset Freeze ,
Belarus ,
Blocked Entities ,
Blocked Person ,
Cryptocurrency ,
Economic Sanctions ,
EU ,
Export Controls ,
General Licenses ,
Imports ,
Most-Favored Nations ,
Russia ,
Trade Relations ,
Trade Restrictions ,
UK ,
Ukraine
On April 29, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced two settlements of potential civil liability with two companies over their apparent violations of its regulations. The...more
5/7/2021
/ Bureau of Industry and Security (BIS) ,
Civil Monetary Penalty ,
Compliance ,
Department of Justice (DOJ) ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Money Transfer ,
Moneygram ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Pass-Through Entities ,
SAP SE ,
SDN List ,
Settlement ,
Subsidiaries ,
Third-Party Risk ,
Voluntary Disclosure
The US government has established new authorities to impose sanctions in response to China’s national security law for Hong Kong, increasing the compliance risks for international banks and other companies that do business in...more
On June 29, 2020, the Commerce Department issued 32 Frequently Asked Questions (FAQs) concerning revision - effective as of the same date - to Part 744.21 of the Export Administration Regulations (EAR). As we discussed in a...more
7/2/2020
/ Bureau of Industry and Security (BIS) ,
China ,
Defense Sector ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Final Rules ,
General Licenses ,
National Security ,
Russia ,
Technology ,
U.S. Commerce Department ,
Venezuela
On May 15, 2020, the US Department of Commerce announced a rule further targeting Chinese telecommunications company Huawei and its chip-making subsidiary HiSilicon for allegedly engaging in “stepped-up efforts to undermine”...more
On April 21, 2020, the US Federal Emergency Management Agency (FEMA) is due to publish a notification of exemptions (Notification) to the restrictions it has recently imposed on the export of five types of personal protective...more
On December 13, 2019, the National Security Division (NSD) of the U.S. Department of Justice (DOJ) issued a revised policy regarding voluntary disclosure of export control and sanctions violations by business organizations...more
12/27/2019
/ Amended Regulation ,
Arms Export Control Act ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Cooperation ,
Department of Justice (DOJ) ,
Directorate of Defense Trade Controls (DDTC) ,
Economic Sanctions ,
Enforcement Guidance ,
Export Administration Regulations (EAR) ,
Export Control Reform Act (ECRA) ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
International Emergency Economic Powers Act (IEEPA) ,
ITAR ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Standards ,
Voluntary Disclosure ,
Willful Blindness ,
Willful Misconduct
On August 1, 2018, the US Department of Commerce Bureau of Industry and Security (BIS) published a Federal Register notice stating that the US government had identified 44 Chinese companies as acting contrary to US national...more
On January 13, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) issued a general license that authorizes all transactions with Sudan that were previously prohibited by the Sudanese Sanctions...more
On October 17, the US Departments of Commerce and the Treasury announced the sixth round of eased sanctions and export controls designed to bolster trade between the United States and Cuba. The amendments by the Bureau of...more
When OFAC added Colombian sports franchise Envigado Fútbol Club to its sanctions list in June 2014, the news conjured up echoes of past dark days of “narco fútbol,” when the tentacles of organized crime touched the country’s...more
9/29/2015
/ Chief Compliance Officers ,
Colombia ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Investment ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
SDN List ,
Trade Relations ,
US Trade Policies